Gabriella Loskorikh

Type of the article: Research Article

Ukrainian transfer pricing legislation demonstrates a significantly higher level of regulatory complexity than international OECD standards, creating a disproportionate burden on the accounting and reporting system. The study aims to quantify the regulatory burden generated by the complexity of Ukrainian transfer pricing legislation through a computational linguistic analysis of its algorithmic characteristics in comparison with international OECD standards. The research methodology is based on Halstead metrics to calculate the algorithmic complexity of regulatory texts, considered as formal structures with the distribution of lexical units into operators and operands. The computational assessment reveals that Ukrainian transfer pricing regulations demonstrate algorithmic complexity 10 to 37 times higher than OECD standards, as the complexity index (L) for Article 39 of the Tax Code of Ukraine equals 2.742 percent versus 0.148 percent for OECD Transfer Pricing Guidelines, while Law of Ukraine No. 4536-IX (Verkhovna Rada of Ukraine, 2023) reaches 5.455 percent, exceeding international benchmarks by 37 times. This excessive complexity directly affects accounting practices, requiring additional resources for recordkeeping, increasing internal control requirements, and increasing the risk of financial reporting errors. The empirical findings demonstrate that excessive algorithmic density directly increases compliance costs for accounting departments, requiring additional resources for interpretation, documentation, and internal control. The study provides quantitative evidence supporting the necessity of systematic simplification of national transfer pricing regulations.